Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Medicine
 
chapter
Regulations Governing the Practice of Behavior Analysis [18 VAC 85 ‑ 150]
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3/29/22  9:35 am
Commenter: Anonymous

On the Petitioner’s “Responses”
 

The trend appears to continue, in that the petitioner finds it necessary to respond to reasonable comments and concerns by citing “inaccurate claims” and the like, however, fails to address the essence and substance of the comments themselves.

Here’s just one example:

Previously, the petitioner expressed concerns that BACB certificants, overall, lack diversity. A recent comment pointed out that QABA does not include measures of diversity on its own website for their certificant base. Instead of addressing this, the petitioner instead claimed that “QABA has an entire operation in Africa working with people of color to get certified as practitioners” and then shares a link. That may be so, but when you access the link, you land on a page of with very little information and no specifics. In addition, the “Learn More” button on the page merely links you back to the different certifications offered by QABA, nothing more.

The petitioner then argues that “QABA has an international standards committee made up of both men and women of color.” While that sounds great, how does that specifically address the fact that the petitioner continues to claim that BACB certificants, overall, lack diversity—all the while fails to produce QABA certificant data on diversity?

The bigger point here is this: Like several previous “responses,” it is difficult to make sense of what’s being presented because they are replete with logical fallacies. More often than not, we are seeing multiple attempts to invalidate a point by presenting nonsymmetrical data, strawman arguments, or information that is completely off-topic. 

CommentID: 120944